### Pennsylvania Department of Environmental Protection

-- Rachel Carson State Office Building P.O. Box 2063 Harrisburg, PA 17105-2063 December

### 7, 2007 

### Secretary 717-787-2814

Mr. Donald S . Welsh Regional Administrator U.S. EPA, Region 

### III (3RAOO) 1650 Arch Street Philadelphia, PA 19103-2029 Re: State Implementation Plan Submission to Meet Obligations Under Section 110(a)(2)(D)(i) for the Eight-Hour Ozone and PM2.5 National Ambient Air Quality Standards (NAAQS) Dear Mr
. Welsh: This letter is being submitted for approval onbehalfofthe Commonwealth ofPennsylvania as a revision to the State Implementation Plan (SIP) to meet the requirements ofthe federal Clean Air Act (CAA) related to interstate pollution transport requirements in accordance with Section 110(a)(2)(D)(i)
.. In accordance ""'lith Section 110(a)(2) ofthe CAA and 40 CPR Section 51.102(d), the PA Department ofEnvironmental Protection (DEP) held a public hearing to receive comments on the proposed SIP revision on October 16, 2007. The commentperiod closed on October 16, 2007. One commentator, the State ofConnecticut, submitted comments on the proposed SIP revision. A comment/response document and proofofpublic notice are enclosed. As discussed below, this SIP revision is consistent with the August 15,2006,William T. Harnett Guidance Memorandum, "Guidance for SIP Submissions to Meet Current Outstanding Obligations Under Section 110(a)(2)(D)(i) for the Eight-Hour Ozone and PM2.5 NAAQS" (HarnettMemorandum). Section 110(a)(l) ofthe CAAprovides that states must adopt and submit SIP revisions to the EPA within three years after the promulgation ofa new or revised NAAQS, meeting the provisions ofSection 110(a)(2) as applicable. Therefore, SIPrevisions addressing the requirements related to Section 110(a)(2) for the eight-hour ozone and the PM2.5 NAAQS were due by statute no later than. July 2000. Due to the litigation ofboth the eight-hour ozone and the PM2.5 NAAQS, the Commonwealth did not submit a SIP revision to satisfy the Section 110(a)(2) requirements byJuly 2000. EPApublished a finding offailure to submit in the Federal Register on April 25, 2005, with an effective date ofMay 25, 2005. The Clean Air Interstate Rule (CAIR) Federal Implementation Plan (FIP) promulgatedbyEPA on April 28, 2006 (71 FR 25328), has partially satisfied this requirement, and the additional measures outlined herein will fully satisfy the pollutant transport provisions in Section 110 ofthe CAA. The August 15, 2006, Harnett Memorandumprovides guidance to the states for meeting the 110(a)(2)(D)(i) requirements.

An Equal Opportunity Employer www.dep.state.pa.us W Printed on Recycled Paper 

# \6<9Mr. Donald S. Welsh



### - 2- December7, 2007
The "goodneighbor" provisions ofSection 110(a)(2)(D)(i) ofthe Act requires the Commonwealth to submit a SIP revision that contains adequate provisions prohibiting any source or other type ofemissions activity within the state from emitting any air pollutant in amounts which will: (I) contribute significantly to nonattainment in, or interfere with maintenance by, any other state with respect to any national primary or secondary air quality standard, or (II) interfere with measures required to be included in the applicable implementation plan for any other state to prevent significant deterioration ofair quality or to protect visibility. 

### Interstate TransportRequirement:

• On May 12,2005, EPApromulgated the CAIR, which determined that 28 states (including Pennsylvania) and the District ofColumbia contribute significantly to nonattainment ofthe eight-hour ozone and PM2.5 NAAQS (70 FR 25162). The CAIRrequires upwind states to revise their SIPs to include control measures to reduce nitrogen oxide and sulfur dioxide emissions to address interstate transport ofozone and PM2.5 precursor emissions. Subsequently, EPApromulgated FIPs on April 28, 2006, for CAIR-covered states to ensure that the reductions are achieved according to the prescribed deadlines (71 FR 25328).
• Electric Generating Units (EGUs) in the Commonwealth are coveredbythe CAIR FIP for annual and seasonal ozone and for sulfur dioxide precursor emissions. The Harnett Memorandum advises that states coveredby CA1R can comply with the Section 110(a)(2)(D)(i) obligations relating to "significant contribution" and "interference with maintenance" requirements by complying with the CAIRrequirements. The Harnett Memorandum further advises that states within the CAIR-covered region need not submit a separate SIP revision to satisfy the Section 110(a)(2)(D)(i) requirements provided that they submit a SIP revision to satisfy CAIR. EGUs in Pennsylvania will continue to beregulated under the FIP until EPA approves Pennsylvania's CAIR final-form regulation as a separate element ofthe SIP. 

### Nonattainment New Source Review (NNSR) and Prevention ofSignificantDeterioration (PSD) Requirements: With respect to NNSR and PSD, the Harnett Memorandum advises that a state may fulfill its Section 110(a)(2)(D)(i) requirements by confirming that: 1. Major stationary sources for eight-hour ozone and PM2.5 are currently subject to PSD and NNSR permitting programs and that states are on track to meet the June 15,2007, deadline for sUbmitting SIPs to address the Phase II ozone implementation rule requirements.

o The Commonwealth confirms that on August 9, 2007, it submitted a SIP revision to EP A for approval that meets the requirements ofthe Phase II Ozone ImplementationMr. Donald S. Welsh

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- December 7, 2007
Rule for NNSR. The federal PSD provisions are incorporatedbyreference in their entirety in the Pennsylvania Code and codified as a SIP revision in 40 CFR 52.2020. Therefore, a PSD SIP revision to implement the Phase II rule was not required. 2. Major sources are subject to PSD and NNSR permitting programs implemented in accordance with EPA's interim guidance calling for use ofPMlO as a surrogate for PM2.5 related to the PSD and NNSRprogram requirements. DEP implements and enforces the PSD and NNSR in all areas ofthe Commonwealth, except Philadelphia and Allegheny counties; those counties administer and enforce·approved local air pollution control programs under Section 12 ofthe Pennsylvania Air Pollution Control Act.
o The Commonwealth confirms that it is meetingthe requirement for the use ofPMlO as a surrogate for PM2.5 in the 

### psI> and NNSRprograms. Visibility Requirement: The EPA's guidance memorandum advises that the Section 110(a)(2)(D)(i)requirement related to protection ofvisibility is deferred until such time as the Commonwealth submits its Regional Haze SIP. The Commonwealth's Regional Haze SIP revision will assess whether there is interference with measures required to be included in the applicable implementation plan for any other state to protect visibility. Conclusion: The Commonwealth confirms that it meets requirements ofSection 110(a)(2)(D)(i) ofthe Act for the eight-hour ozone and the PM2.5 NAAQS and does not significantly contribute to

. nonattainment or interference with maintenance ofthe NAAQS in another state. Ifyou have any questions regarding this submittal orrequire additional information, please contact Joyce E. Epps, Director, Bureau ofAir Quality, bye-mail atjeepps@state.pa.us orbytelephone at 717-787-9702. Sincerely,

Enclosure

### Mr. Donald S .Welsh



### - 4- December 7, 2007
bee: WARM J. Epps 

### A. Shulman ARM Reading File